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Data Protection Policy

Introduction

Serangoon Gardens Country Club respects the privacy and confidentiality of your personal data. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data that you provide to us as a member, prospect, client, employee, job seeker, partner or anyone who comes into contact with us.

We have developed this Data Protection Policy in compliance with the Singapore Personal Data Protection Act (PDPA) 2012 to assist you in understanding how we collect, use, disclose, process and retain your personal data.

This Policy forms part of the terms and conditions, if any, governing your specific relationship with us and should be read in conjunction with such terms and conditions. In the event of any conflict between the provisions of this Policy and the said terms and conditions, the provisions of the terms and conditions shall prevail to the fullest extent permissible by law.

How We Collect Your Personal Data

The PDPA defines personal data as “data, whether true or not, about an individual who can be identified a) from that data; or b) from that data and other information to which the organisation has or is likely to have access.”

We collect the personal data of you when you fill up an application or registration form (physical or online), enquire about our services or products, visit our outlets or website, interact with us on social media platforms, participate in our events, activities, referral programmes or contests; provide your feedback to us, seek employment with us or interact with us in any manner.

Types of Personal Data We Collect About You

The types of personal data we collect about you may include your name, membership number, identification numbers such as Singapore NRIC/FIN numbers or passport numbers, date of birth, personal contact information, photos & video footage.

How We Use Your Personal Data

We use the personal data we have collected about you for purposes of managing our relationship with you, delivering and improving our products and services, conducting surveys, notifying you of Club updates or promotions, publishing photos and videos of Club organized events in our online and offline publications for marketing and promotion uses. We do not sell your personal data to third parties such as advertisers. However, we allow advertisers to provide their promotional materials to the Club to be inserted with the Club’s mailings to you or to advertise in our Club’s offline or online publications.

Who We Disclose Your Personal Data To

We disclose some of the personal data we have collected about you to the parties or organisations outside Serangoon Gardens Country Club solely for the fulfilment of our obligations to you in delivering our products and services as well as to fulfil any regulatory or legal requirements.

How We Manage the Collection, Use and Disclosure of Your Personal Data

We are committed to implementing policies, practices and processes for data protection that comply closely with the PDPA obligations. These are elaborated in the rest of this Policy document.

1) Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. As far as possible, we will not collect more personal data than necessary for the stated purpose.

2) Third-Party Consent

By providing personal data relating to a third party (e.g. information of your spouse, children or childminders) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use or disclose of his/her personal data.

3) Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted. Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUB” feature in an SMS or online service.

Accessing and Making Correction to Your Personal Data

You may write in to us, based on reasonable grounds, to find out how we have been using or disclosing your personal data and to make any correction if there is any error or omission. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will try to respond to your request within 30 days. By which time we will give you an estimate of how long it is going to take to retrieve all the relevant data, and how much we will charge you for processing the request.

Accuracy of Your Personal Data

We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we will do a verification exercise for you to update us on any changes to your personal data. If you are a member, it is important that you update us if there are any changes in your personal information such as your mailing address.

Protection of Personal Data

We will take the necessary security arrangements to protect your personal data that is under our charge or control to prevent unauthorised access, collection, use, disclosure, or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

External data intermediaries who process and maintain your personal data on our behalf will be bound by contractual data security arrangements we have with them and they are not allowed to use the personal data supplied other than for the purpose of fulfilling their contractual obligation with us.

Retention of Personal Data

We will not retain any of your personal data under our charge or control when it is no longer necessary for any business or legal purposes. Personal data that is no longer needed will be destroyed or disposed of in a secure manner. This applies to both paper documents and electronic data stored in databases.

Transfer of Personal Data

If there is a need for us to transfer your personal data to another country, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that inSingapore.

Amendments to Data Protection Policy

We may revise our Data Protection Policy from time to time. You may also obtain a copy of the latest version at the Club’s Main Reception.

Contacting Us

If you have any questions about our collection, use, and/or disclosure of your personal data; feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer at: dpo@sgcc.com.sg or write in to us at: 22 Kensington Park Road, Singapore 557 271.

Any query or complaint should include, at least, the following details:

Full name and contact information of the data subject

Brief description of the query or complaint

We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.

Serangoon Gardens Country Club is a family-friendly club with an Olympic-sized swimming pool, wading pool, water play area, gym, bowling alley and other sports and dining facilities. The Club sits on a 999-year leasehold prime land and comprises of 3 buildings housing various facilities for members.